Message to the Senate Transmitting the United States-New Zealand Convention on Taxation and
Fiscal Evasion

August 13, 1982
To the Senate of the United States:

I transmit herewith, for Senate advice and consent to ratification, a Convention between the
United States of America and New Zealand for the avoidance of double taxation and the
prevention of fiscal evasion with respect to taxes on income, together with a related Protocol,
signed at Wellington on July 23, 1982. I also transmit the report of the Department of State on
the Convention.

The Convention, based on the OECD and draft United States model income tax conventions,
takes into account changes in the income tax laws and tax treaty policies of the two countries. It
provides limits on the tax at source with respect to taxes on investment income and provides rules
for the taxation of capital gains, business profits, personal service income and other income. It
also specifies the method used to avoid double taxation and provides for administrative
cooperation between the tax officials of the two countries to avoid double taxation and prevent
fiscal evasion.

I recommend that the Senate give early and favorable consideration to the Convention and related
Protocol and give advice and consent to their ratification.